Abstract
This article examines the principal non-real-estate routes through which a foreign investor may seek exceptional acquisition of Turkish citizenship. It considers fixed capital investment, qualifying bank deposits, Turkish government debt instruments, real estate and venture capital investment fund shares, participation in the private pension system and employment creation. The analysis distinguishes the investment threshold from the later citizenship decision, explains the role of the sector-specific certifying authorities, and addresses the three-year maintenance rules, currency conversion requirements, source-of-funds compliance and family applications. It also identifies two important corrections to common market descriptions: the current regulation does not simply permit every route to be funded in Turkish lira at the outset, and different investment routes should not be treated as interchangeable for initial qualification, even though the regulation permits transition between investment types for completion of the required holding period.
Keywords: Turkish citizenship by investment; exceptional citizenship; fixed capital investment; bank deposit; government bonds; investment funds; private pension; employment creation
Introduction
Turkish citizenship by investment is often discussed as if it were a single real-estate programme. It is not. The legal framework contains several alternative investment and employment routes, each with its own threshold, certifying authority and documentary logic. A foreign investor who already intends to establish a business, maintain treasury funds in Türkiye, hold Turkish capital-market instruments or employ a substantial workforce may therefore have a route that fits the underlying commercial plan more naturally than a property acquisition.
The starting point is exceptional acquisition under Article 12 of Turkish Citizenship Law No. 5901, read together with Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law. Meeting an investment criterion allows the file to proceed within that exceptional framework, but it does not create an automatic entitlement to citizenship. The security and public-order assessment and the final Presidential decision remain separate stages.1
1. The Current Non-Real-Estate Routes and Their Authorities
As of the review date, the official investment framework identifies five principal non-real-estate investment routes relevant to this article: fixed capital investment; a qualifying bank deposit; Turkish government debt instruments; real estate investment fund or venture capital investment fund shares; and a qualifying private-pension contribution. The headline amount for each of those routes is USD 500,000, subject to the route-specific currency and transaction rules described below. A separate employment route requires the creation of at least 50 jobs. Certification is divided among the Ministry of Industry and Technology, Banking Regulation and Supervision Agency, Ministry of Treasury and Finance, Capital Markets Board, Insurance and Private Pension Regulation and Supervision Agency, and Ministry of Labour and Social Security, respectively.2
Currency wording should be checked route by route rather than reduced to one formula. The Ministry of Industry and Technology still describes the fixed-capital route as at least USD 500,000 or the equivalent in foreign currency or Turkish lira, while the current central investment guide states USD 500,000 or equivalent foreign currency. By contrast, the bank-deposit, government-debt, fund-share and private-pension routes are subject to the post-2022 foreign-exchange sale mechanism: the relevant foreign currency is sold through a bank to the Central Bank before the qualifying Turkish-lira transaction is completed. For that reason, an investor should confirm the current route-specific procedure before transferring funds rather than rely on an older generic description.3
2. Fixed Capital Investment: Suitable for a Genuine Turkish Business Project
The fixed-capital route applies where the Ministry of Industry and Technology determines that the foreign investor has made a qualifying fixed capital investment meeting the applicable USD 500,000 threshold. The Ministry’s current public materials continue to refer to USD 500,000 or the equivalent in foreign currency or Turkish lira. This route is most relevant where the investor genuinely intends to own or expand an operating enterprise rather than place money in a passive financial asset.4
The legal threshold is only the starting point. The Ministry applies its own implementation principles to identify the investment, the applicant and the amount attributable to that applicant. For an investment made through a company, the ownership structure, the company records, the source and timing of the capital and the nature of the qualifying fixed investment should be reconciled before the application for a conformity certificate is filed. A capital injection should not be described as qualifying merely because money entered a corporate bank account.
The Ministry’s published citizenship framework also uses an undertaking designed to preserve the qualifying investment. In practice, the investor should assume that disposal of the qualifying shareholding, transfer of the relevant investment or a capital reduction during the protected period can affect continuing eligibility and should obtain advice before any restructuring, financing or exit.5
3. Bank Deposit Route: The Three-Year Rule and the Currency-Conversion Step
The bank deposit route requires at least USD 500,000 or equivalent foreign currency to be placed through a bank operating in Türkiye, with the qualifying deposit maintained for at least three years and the investment certified by the Banking Regulation and Supervision Agency. The operational framework is more specific than the phrase “deposit USD 500,000 in a Turkish bank” suggests.6
Under the current currency-conversion rules, the relevant foreign currency is sold to a bank for sale to the Central Bank, and the resulting Turkish-lira amount is held in a Turkish-lira deposit for the three-year period. The bank used for the foreign-exchange sale and the bank holding the Turkish-lira deposit must be the same under the Central Bank instruction. This creates real currency exposure and should be understood before funds are committed.7
Source-of-funds and customer-due-diligence review is a separate compliance layer. Banks remain subject to Turkish anti-money-laundering rules and may require documentary evidence concerning identity, beneficial ownership, occupation, expected account activity and the origin of funds. A conformity threshold does not override the bank’s AML obligations, and there is no sound basis for promising that every compliant applicant will be onboarded on identical terms by every bank.8
4. Government Bonds: Asset Preservation Does Not Mean Price Certainty
The government debt route requires at least USD 500,000 or equivalent foreign currency to be invested in qualifying Turkish government debt instruments and maintained for at least three years, with certification by the Ministry of Treasury and Finance. The current foreign-exchange instruction requires the qualifying currency to be converted through the Central Bank mechanism before the resulting Turkish-lira amount is invested in Turkish-lira government debt instruments.9
The investment should be structured around the holding requirement rather than a short-term trading strategy. The Treasury’s published procedures recognise that income from the instruments may be used by the investor, while the qualifying securities themselves remain subject to the prescribed blocking and maintenance rules. Maturity, coupon structure, market price and reinvestment should therefore be planned so that the citizenship condition and the investment strategy do not work against each other.10
5. Investment Fund Shares: SPK Certification and Continuous Ownership
A foreign investor may qualify by acquiring at least USD 500,000 or equivalent foreign currency of participation shares in a real estate investment fund, gayrimenkul yatırım fonu, or venture capital investment fund, girişim sermayesi yatırım fonu, and holding the qualifying shares for at least three years. The Capital Markets Board, SPK, certifies this route.11
The SPK procedure is highly documentary. The qualifying participation shares are tracked through the Central Registry Agency, MKK, and the official procedure requires the relevant shares to be blocked in a citizenship sub-account. SPK also states that the qualifying foreign currency must be sold through the prescribed Central Bank mechanism before the fund purchase. The investor should therefore coordinate the bank, the fund transaction, the MKK account and the certification application as one sequence rather than as separate administrative tasks.12
Market-value movements after qualification require careful distinction from voluntary disposal. SPK’s current procedure provides that a fall in the fund value caused by exchange-rate movement does not by itself defeat the citizenship application, while a voluntary sale, transfer or other transaction reducing the qualifying holding during the three-year period can trigger notification to the authorities. The risk analysis should therefore focus on both investment volatility and compliance with the ownership restriction.13
6. Private Pension Route: A Citizenship Investment, Not an Ordinary Retail Pension Decision
The private pension route requires at least USD 500,000 or equivalent foreign currency to be contributed to the Turkish private pension system, kept in funds designated within the regulatory framework and maintained in the system for at least three years. Certification is provided by the Insurance and Private Pension Regulation and Supervision Agency, SEDDK.14
The same Central Bank conversion framework applies before the contribution is placed into the relevant pension funds. SEDDK has also clarified that a foreign investor making the citizenship contribution does not receive the ordinary Turkish state contribution merely because the money enters the pension system, because the investor has not yet acquired Turkish citizenship at that stage. The economic comparison should therefore use the actual citizenship-plan rules rather than assume the incentives applicable to an ordinary Turkish participant.15
7. Employment Creation: Fifty Jobs Is a Continuing Operational Test
The employment route does not require a USD 500,000 capital threshold. It requires the foreign applicant to create employment for at least 50 people, with certification by the Ministry of Labour and Social Security. The Ministry’s current procedure is directed to a foreign natural person who owns or is a shareholder in the relevant workplace or workplaces and requires documentary evidence from the Trade Registry, Social Security Institution and tax and social-security records.16
This route should not be reduced to a one-day headcount. The Ministry’s current procedure requires at least 50 Turkish citizens to have been employed continuously for at least six months retrospectively from the application date, and states that the employment must be maintained for at least two years after the application date. The Ministry also assesses whether the applicant’s ownership and capital share are at a sufficient level. For a labour-intensive business, employment planning, payroll compliance and ownership structure should therefore be reviewed together before citizenship is treated as a realistic outcome.17
8. Certificate of Conformity, Residence Permit and Citizenship Application
The conformity certificate is the bridge between the investment and the citizenship process. Each route has a designated authority that confirms whether the investment or employment condition has been satisfied. The National Population and Citizenship Directorate’s investor procedure then links that conformity process with the investment-based short-term residence permit under Article 31(1)(j) of Law No. 6458 and the exceptional citizenship application.18
The investment certificate is not the citizenship decision. The applicant still needs the citizenship file, civil-status documents and the security and public-order assessment. Official investor procedures provide for coordinated handling of residence and citizenship applications through designated offices and require the certifying institution to communicate the conformity result to the relevant migration and citizenship authorities.19
For foreign documents, names, dates of birth, marital status and parent-child relationships should be made consistent before submission. Apostille or other legalisation, Turkish translation and notarisation requirements should be planned by document and country. A technically qualifying investment does not cure an inconsistent civil-status file.
9. Family Members, Multiple Nationality and the Scope of the Application
Article 12 of Law No. 5901 extends the exceptional route to the qualifying foreign investor’s foreign spouse and to the investor’s and spouse’s minor or dependent foreign children, provided the statutory security and public-order conditions are satisfied. This is broader than describing the rule only as “children under eighteen”, but dependency must be supported where the child is an adult.20
Turkish law also recognises multiple nationality. The acquisition of Turkish citizenship does not, as a general Turkish-law rule, require the applicant to renounce every existing nationality. The legal consequences in the applicant’s other country or countries must nevertheless be checked separately, because retention, declaration, military-service or tax consequences can be governed by foreign law.21
10. Three-Year Maintenance, Route Changes and the Risk of Losing the Basis of Citizenship
The maintenance obligation does not operate identically across every route. Bank deposits, government debt instruments, qualifying fund shares and the private-pension route expressly use a three-year maintenance requirement. The fixed-capital route is implemented through Ministry procedures and undertakings designed to preserve the qualifying investment. The employment route follows a different continuity rule: the Ministry currently requires six months of continuous qualifying employment before the conformity application and maintenance of the qualifying employment for at least two years after the application date. A publication should therefore avoid describing every route as subject to one identical three-year clause.22
Another common oversimplification concerns switching between routes. Article 20(8) of the Implementing Regulation permits transition between investment types for the purpose of completing the required period. That does not mean that an applicant should simply add smaller amounts from different routes to manufacture the initial USD 500,000 threshold. Initial qualification and later transition are different questions, and any proposed switch should be cleared with the authorities before the original investment is released.23
The National Population and Citizenship Directorate’s investor procedure expressly states that the qualifying conditions must continue for the prescribed period. If the certifying authority determines that the conditions have been lost, it must notify the citizenship and migration authorities, and cancellation action may follow under the citizenship legislation. A sale, withdrawal, pledge, transfer or restructuring during the protected period should therefore be treated as a legal event requiring advance review, not as a routine portfolio decision.24
11. Judicial Perspective: Investment Qualification Is Not a Guaranteed Citizenship Right
Citizenship disputes are administrative-law matters. They are not ordinarily a field in which Yargıtay, the Court of Cassation, supplies the controlling appellate jurisprudence. The relevant judicial framework comes from the administrative courts, regional administrative courts and, where constitutional rights are engaged, the Constitutional Court.
The Constitutional Court’s A.S. decision, Application No. 2018/31431, dated 3 March 2022, was not an investment-citizenship case. It concerned a refusal of citizenship under the general naturalisation framework. Its importance is narrower but still useful: where an administrative decision interferes with protected private life, the reasons relied upon must be connected to concrete facts and capable of judicial scrutiny. It does not turn satisfaction of an investment threshold into an automatic right to citizenship.25
An official article published in Danıştay Dergisi in 2025 also reports Ankara Regional Administrative Court, 10th Administrative Case Division, E. 2024/4355, K. 2024/9343, 31 December 2024, as treating exceptional citizenship as an area in which the administration has particularly broad discretion grounded in sovereignty, even where statutory conditions are met. The practical consequence is that counsel should distinguish the conformity certificate from the final citizenship decision and avoid language suggesting that certification guarantees the outcome.26
12. Practical Due Diligence Before Funds Are Committed
Before selecting a route, the investor should compare the legal and commercial consequences of each option. A fixed capital investment may fit a business expansion but brings corporate and exit issues. A bank deposit is operationally simpler but creates currency and bank-risk considerations. Government debt and fund shares introduce market exposure. A private-pension route has its own plan and fund restrictions. Employment creation is an operating-business commitment, not a paper investment.
Counsel should therefore obtain the current authority rules, identify the precise transaction sequence, confirm who must own the asset or business, document the source of funds, and map the three-year or continuity obligations before any irreversible transfer. The client should also be told which parts of the process are legal, which are financial and which depend on a regulator or public authority. A lawyer can structure and document the file; a lawyer cannot responsibly guarantee the final exercise of governmental discretion.
Frequently Asked Questions
Can I combine several investment routes to reach USD 500,000?
The safer legal position is that initial qualification should satisfy the full threshold of a selected route rather than simply adding unrelated partial investments together. The regulatory framework does, however, recognise transitions between qualifying investment types for the purpose of completing the required maintenance period, subject to the applicable authority procedures. That is different from aggregating partial amounts to establish initial qualification. Any proposed switch should be cleared with the relevant authorities before the original investment is released.
Do I have to keep every investment for exactly three years?
No. The maintenance rule depends on the route. Bank deposits, government debt instruments, qualifying fund shares and the private-pension route expressly use a three-year period. The fixed-capital route is subject to its Ministry preservation requirements. The employment route currently requires at least six months of continuous qualifying employment before the application and maintenance of the qualifying employment for at least two years after the application date.
Can I keep the USD 500,000 bank deposit in dollars for three years?
The current operational framework requires the relevant foreign currency to be sold through a bank to the Central Bank and the resulting Turkish-lira amount to be held in a qualifying Turkish-lira deposit. The currency-conversion and deposit steps should therefore be planned together with the bank before funds are transferred.
Can my spouse and children be included?
The exceptional citizenship framework covers the qualifying investor’s foreign spouse and the investor’s and spouse’s minor or dependent foreign children, subject to the required documentation and the national-security and public-order assessment.
Does obtaining a conformity certificate guarantee citizenship?
No. The certificate confirms the investment or employment condition for the relevant route. Exceptional citizenship remains subject to the citizenship file, security and public-order review, and the final decision by the competent authority.
What happens if I sell, transfer or withdraw the qualifying investment early?
The relevant certifying authority can report loss of the qualifying condition to the citizenship and migration authorities. Official investor procedures contemplate cancellation action where the required condition is lost during the prescribed period. Advice should be obtained before changing the investment structure.
How long does the process take?
There is no single legally guaranteed completion time for the entire citizenship process. Some conformity authorities publish short internal processing periods for complete files, but the residence, security and citizenship stages are separate. A professional article should therefore avoid promising a universal number of months.
Conclusion
The non-real-estate citizenship routes are not interchangeable products carrying one generic USD 500,000 rule. Each route has a specific certifying authority, transaction sequence and maintenance condition. The practical differences are substantial. A bank deposit or government bond is a financial holding. A fund investment is a regulated capital-market position. A private-pension contribution sits within the pension framework. Fixed capital and employment routes are tied to an operating business.
For foreign investors, the most reliable strategy is to choose the route that matches the underlying commercial objective and then build the citizenship file around the current authority rules. Thresholds, currency-conversion steps, ownership, blocking arrangements, employment continuity, family documents and the protected period should be confirmed before funds are committed. The conformity certificate is a necessary milestone, but exceptional citizenship remains a public-law decision and should never be marketed as an automatic result.
Bibliography
Legislation and Official Regulatory Materials
Turkish Citizenship Law No. 5901, 29 May 2009, especially Articles 12, 31 and 44. Turkish Grand National Assembly official enacted text and subsequent amendments.
Law No. 6458 on Foreigners and International Protection, especially Article 31(1)(j), as amended.
Regulation on the Implementation of the Turkish Citizenship Law, Council of Ministers Decision No. 2010/139, especially Article 20, as amended by the Presidential Decisions published in Official Gazette Nos. 30540, 31711, 31834 and later amendments.
Türkiye Cumhuriyet Merkez Bankası, Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik Kapsamında Türkiye Cumhuriyet Merkez Bankasına Yapılacak Döviz Satışına İlişkin Uygulama Talimatı, current published instruction.
Judicial Decisions
Constitutional Court, A.S., Application No. 2018/31431, 3 March 2022, official press summary published 17 June 2022.
Ankara Regional Administrative Court, 10th Administrative Case Division, E. 2024/4355, K. 2024/9343, 31 December 2024, reported in T.C. Danıştay Dergisi, Issue 160, July 2025.
Institutional and Official Materials
Presidency of the Republic of Türkiye Investment and Finance Office, Acquiring Property and Citizenship, current investment-route summary, https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx.
Republic of Türkiye Ministry of Industry and Technology, Sabit Sermaye Yatırımı Karşılığı Vatandaşlık Uygulaması, current official support page and implementation materials, https://sanayi.gov.tr/destek-ve-tesvikler/yatirim-tesvik-sistemler.
Republic of Türkiye Ministry of Labour and Social Security, Directorate General of International Labour Force, İstisnai Türk Vatandaşlığı / Exceptional Turkish Citizenship, current employment-route procedure, https://www.csgb.gov.tr/uigm/tr/genel-bilgi/%C4%B1stisnai-turk-vatandasligi/.
Capital Markets Board of Türkiye, Yabancıların Yatırım Yapmak Suretiyle İstisnai Türk Vatandaşlığı Kazanımı, current fund-share certification procedure, https://www.spk.gov.tr/yatirimcilar/yabancilarin-yatirim-yapmak-suretiyle-istisnai-turk-vatandasligi-kazanimi.
Insurance and Private Pension Regulation and Supervision Agency, BES participation for exceptional Turkish citizenship, official information note and current circular materials, https://seddk.gov.tr/.
Republic of Türkiye Ministry of Treasury and Finance, procedure for exceptional citizenship through government debt instruments, official procedure materials.
Financial Crimes Investigation Board, Frequently Asked Questions, customer due diligence and exceptional citizenship banking questions, https://masak.hmb.gov.tr/sikca-sorulan-sorular.
Directorate General of Population and Citizenship Affairs, procedures for foreign investors seeking exceptional Turkish citizenship, official instruction on conformity, residence and citizenship processing, https://www.nvi.gov.tr/.
Directorate General of Population and Citizenship Affairs, guidance on multiple nationality under Article 44 of Law No. 5901, https://www.nvi.gov.tr/.
Republic of Türkiye Council of State, Danıştay Dergisi, Issue 160, July 2025, article discussing administrative discretion in citizenship acquisition.
Footnotes
1. Turkish Citizenship Law No. 5901, art. 12(1)(b), read with Law No. 6458 on Foreigners and International Protection, art. 31(1)(j), and the Regulation on the Implementation of the Turkish Citizenship Law, art. 20. The current official investment guide states that qualifying investors may be eligible for exceptional citizenship subject to a decision of the President. Presidency of the Republic of Türkiye Investment and Finance Office, “Acquiring Property and Citizenship,” current version, https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx.
2. Presidency of the Republic of Türkiye Investment and Finance Office, “Acquiring Property and Citizenship,” current route summary: fixed capital USD 500,000; bank deposit USD 500,000 held for at least three years; government bonds USD 500,000 held for at least three years; qualifying GYF/GSYF shares USD 500,000 held for at least three years; qualifying private-pension contribution USD 500,000 maintained for at least three years; and creation of at least 50 jobs. https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx.
3. Republic of Türkiye Ministry of Industry and Technology, “Sabit Sermaye Yatırımı Karşılığı Vatandaşlık Uygulaması,” current official page, which continues to describe fixed capital as USD 500,000 or equivalent foreign currency or Turkish lira, https://sanayi.gov.tr/destek-ve-tesvikler/yatirim-tesvik-sistemler. For the post-2022 currency-conversion mechanism applicable to Regulation art. 20(2)(b), (ç), (d), (e) and (f), see Türkiye Cumhuriyet Merkez Bankası, “Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik Kapsamında Türkiye Cumhuriyet Merkez Bankasına Yapılacak Döviz Satışına İlişkin Uygulama Talimatı,” arts. 1 and 4, current published instruction, https://www.tcmb.gov.tr/wps/wcm/connect/TR/TCMB+TR/Main+Menu/Banka+Hakkinda/Mevzuat/Operasyon+Mevzuat.
4. Republic of Türkiye Ministry of Industry and Technology, “Sabit Sermaye Yatırımı Karşılığı Vatandaşlık Uygulaması,” current official support page and linked implementation materials, https://sanayi.gov.tr/destek-ve-tesvikler/yatirim-tesvik-sistemler. The Ministry is the certifying authority for the fixed-capital route.
5. Republic of Türkiye Ministry of Industry and Technology, fixed-capital citizenship implementation materials and undertaking forms published through the Ministry’s citizenship support page. The preservation terms should be checked in the current Ministry forms before any share transfer, capital reduction, restructuring or exit. https://sanayi.gov.tr/destek-ve-tesvikler/yatirim-tesvik-sistemler.
6. Presidency of the Republic of Türkiye Investment and Finance Office, “Acquiring Property and Citizenship,” bank-deposit route: at least USD 500,000 or equivalent foreign currency in a bank operating in Türkiye, not withdrawn for at least three years, certified by the Banking Regulation and Supervision Agency. https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx.
7. Türkiye Cumhuriyet Merkez Bankası, “Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik Kapsamında Türkiye Cumhuriyet Merkez Bankasına Yapılacak Döviz Satışına İlişkin Uygulama Talimatı,” current published instruction. The instruction governs the sale of the relevant foreign currency to a bank for onward sale to the Central Bank before transactions under Regulation art. 20(2)(b), (ç), (d), (e) and (f), and contains the route-specific rules for the resulting Turkish-lira transaction. https://www.tcmb.gov.tr/wps/wcm/connect/TR/TCMB+TR/Main+Menu/Banka+Hakkinda/Mevzuat/Operasyon+Mevzuat.
8. Financial Crimes Investigation Board (MASAK), “Sıkça Sorulan Sorular,” customer identification, customer due diligence, risk-based monitoring and exceptional-citizenship banking questions under Law No. 5549 and the Measures Regulation. https://masak.hmb.gov.tr/sikca-sorulan-sorular. Citizenship eligibility does not displace the bank’s separate AML/CFT obligations.
9. Presidency of the Republic of Türkiye Investment and Finance Office, “Acquiring Property and Citizenship,” government-bond route; and Türkiye Cumhuriyet Merkez Bankası, citizenship foreign-exchange sale instruction, applicable to Regulation art. 20(2)(d). https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx; https://www.tcmb.gov.tr/wps/wcm/connect/TR/TCMB+TR/Main+Menu/Banka+Hakkinda/Mevzuat/Operasyon+Mevzuat.
10. Republic of Türkiye Ministry of Treasury and Finance, “İstisnai Vatandaşlık Edinimine İlişkin Usul ve Esaslar,” 2026 official procedure for government debt instruments, including the three-year maintenance monitoring and rules on transitions between investment types. https://ms.hmb.gov.tr/uploads/2026/06/Istisnai-Vatandaslik-Edinimine-Iliskin-Usul-ve-Esaslar-dfca5f1dfdfe4b54.pdf.
11. Capital Markets Board of Türkiye (SPK), “Yabancıların Yatırım Yapmak Suretiyle İstisnai Türk Vatandaşlığı Kazanımı,” current procedure under Regulation art. 20(2)(e): at least USD 500,000 or equivalent foreign currency of qualifying real estate investment fund or venture capital investment fund participation shares, held for at least three years. https://spk.gov.tr/yatirimcilar/yabancilarin-yatirim-yapmak-suretiyle-istisnai-turk-vatandasligi-kazanimi.
12. SPK, current exceptional-citizenship procedure, requiring the relevant GYF/GSYF participation shares to be tracked through MKK and placed in the “Vatandaşlık Blokaj Alt Hesabı,” and confirming the pre-purchase foreign-exchange sale through a bank and the Central Bank. https://spk.gov.tr/yatirimcilar/yabancilarin-yatirim-yapmak-suretiyle-istisnai-turk-vatandasligi-kazanimi.
13. SPK, current exceptional-citizenship procedure, paras. concerning continuous three-year ownership, exchange-rate movements and investor-initiated sales or transfers. The procedure states that a fall below USD 500,000 caused by exchange-rate movement does not by itself defeat the application, while investor-initiated reductions in the qualifying holding are separately monitored. https://spk.gov.tr/yatirimcilar/yabancilarin-yatirim-yapmak-suretiyle-istisnai-turk-vatandasligi-kazanimi.
14. Insurance and Private Pension Regulation and Supervision Agency (SEDDK), “Bireysel Emeklilik Sistemine Katkı Payı Yatırmak Suretiyle Vatandaşlık veya Uzun Dönemli İkamet İzni Başvurusunda Bulunacak Yabancılar için Açıklama,” describing the USD 500,000 or equivalent foreign-currency contribution, designated funds and three-year participation requirement. https://seddk.gov.tr/upload/doc/BES-aciklama.pdf.
15. SEDDK, public announcement concerning state contribution for foreign participants seeking exceptional citizenship, 13 May 2022. The announcement explains that a foreign participant making the qualifying citizenship contribution cannot receive the ordinary state contribution at that stage because the participant has not yet acquired Turkish citizenship. https://seddk.gov.tr/upload/Ana%20Sayfa%20g%C3%BCncel/BES-duyuru.pdf.
16. Republic of Türkiye Ministry of Labour and Social Security, Directorate General of International Labour Force, “İstisnai Türk Vatandaşlığı / Exceptional Turkish Citizenship,” current procedure for foreigners who create employment for at least 50 people in workplaces they own or in which they are shareholders. The required documents include Trade Registry and Social Security records and tax/social-security status documents. https://www.csgb.gov.tr/uigm/tr/genel-bilgi/%C4%B1stisnai-turk-vatandasligi/.
17. Republic of Türkiye Ministry of Labour and Social Security, Directorate General of International Labour Force, current “Exceptional Turkish Citizenship” procedure. The Ministry states that at least 50 Turkish citizens must be employed continuously for at least six months retrospectively from the application date and that the employment must be maintained for at least two years after the application date; it also assesses whether the applicant’s ownership and capital share are sufficient. https://www.csgb.gov.tr/uigm/en/general-information/exceptional-turkish-citizenship/.
18. Turkish Citizenship Law No. 5901, art. 12(1)(b), and Law No. 6458 on Foreigners and International Protection, art. 31(1)(j), read with the current sector-specific conformity procedures. Presidency of the Republic of Türkiye Investment and Finance Office, “Obtaining a Residence Permit,” current investment-based residence framework, https://www.invest.gov.tr/en/investmentguide/pages/obtaining-a-residence-permit.aspx.
19. Directorate General of Population and Citizenship Affairs (NVI), official procedures governing citizenship applications by foreign investors, read with the route-specific conformity procedures of the competent authority. The conformity certificate, investment-based residence permit and citizenship determination are separate stages. See also Turkish Citizenship Law No. 5901, art. 12, and Law No. 6458, art. 31(1)(j), https://www.nvi.gov.tr/.
20. Turkish Citizenship Law No. 5901, art. 12(1)(b), as amended, and the Ministry of Labour and Social Security’s current exceptional-citizenship guidance. The framework covers the qualifying investor’s foreign spouse and the investor’s and spouse’s minor or dependent foreign child, subject to national-security and public-order conditions. https://www.csgb.gov.tr/uigm/tr/genel-bilgi/%C4%B1stisnai-turk-vatandasligi/.
21. Turkish Citizenship Law No. 5901, art. 44; Directorate General of Population and Citizenship Affairs, official multiple-nationality implementation guidance. NVI records multiple nationality where the statutory documentary conditions are met. https://www.nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/genelge/5901Sayili_Turk_Vatandasligi_Kanuna_Gore_Aciklama2009.pdf.
22. For the express three-year requirements, see the current Investment and Finance Office route summary for bank deposits, government bonds, fund shares and private pension. For employment, the Ministry of Labour and Social Security currently requires six months of continuous qualifying employment before application and maintenance for at least two years after application. Fixed-capital preservation is governed by the Ministry of Industry and Technology’s implementation materials. https://www.invest.gov.tr/en/investmentguide/pages/acquiring-property-and-citizenship.aspx; https://www.csgb.gov.tr/uigm/en/general-information/exceptional-turkish-citizenship/; https://sanayi.gov.tr/destek-ve-tesvikler/yatirim-tesvik-sistemler.
23. Regulation on the Implementation of the Turkish Citizenship Law, art. 20(8), concerning transitions between qualifying investment types for completion of the required period. See also Republic of Türkiye Ministry of Treasury and Finance, “İstisnai Vatandaşlık Edinimine İlişkin Usul ve Esaslar,” art. 7, 2026, which sets out authority-specific transition procedures for government-debt applications. https://ms.hmb.gov.tr/uploads/2026/06/Istisnai-Vatandaslik-Edinimine-Iliskin-Usul-ve-Esaslar-dfca5f1dfdfe4b54.pdf.
24. Turkish Citizenship Law No. 5901, art. 31, read with the official investor procedures and route-specific monitoring rules. SPK’s current procedure, for example, requires notification to the migration and citizenship authorities when the qualifying fund-share conditions cease to be met. https://spk.gov.tr/yatirimcilar/yabancilarin-yatirim-yapmak-suretiyle-istisnai-turk-vatandasligi-kazanimi. The legal effect of a particular change must be assessed on the specific facts and applicable route.
25. Constitutional Court, A.S. [First Section], Application No. 2018/31431, 3 March 2022, Official Gazette No. 31869, 17 June 2022. The case concerned refusal of a general naturalisation application and the right to respect for private life; it was not a citizenship-by-investment decision. Official decision database: https://kararlarbilgibankasi.anayasa.gov.tr/BB/2018/31431.
26. Yılmaz Burunkaya, “Evlenme Yoluyla Türk Vatandaşlığının Kazanılmasında İdarenin Takdir Yetkisi,” T.C. Danıştay Dergisi, Issue 160, July 2025, pp. 263-316, reporting Ankara Regional Administrative Court, 10th Administrative Case Division, E. 2024/4355, K. 2024/9343, 31 December 2024. The article discusses the broad administrative discretion associated with citizenship decisions as exercises of sovereign authority. Official journal: https://dergi.danistay.gov.tr/documents/Dan%C4%B1%C5%9Ftay%20Dergisi%20160%20%283%29.pdf.
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